SHRI. AJITH R,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, MYSORE

In the result, both the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

penalty u/s. 271(1)(c) of the Act. ITA No.1866 to 1870/B/18 & Ors. Page 2 of 18 2. The assessee in the above appeals is Mr.R.Ajith. He is assessed in the status of an individual. He is engaged in real estate business. There was a survey u/s. 133A

R.AJITH ,MYSORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), MYSORE

In the result, both the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

penalty u/s. 271(1)(c) of the Act. ITA No.1866 to 1870/B/18 & Ors. Page 2 of 18 2. The assessee in the above appeals is Mr.R.Ajith. He is assessed in the status of an individual. He is engaged in real estate business. There was a survey u/s. 133A

SHRI. K. RAMASWAMY,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE--2(1),, MYSORE

In the result, both the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

penalty u/s. 271(1)(c) of the Act. ITA No.1866 to 1870/B/18 & Ors. Page 2 of 18 2. The assessee in the above appeals is Mr.R.Ajith. He is assessed in the status of an individual. He is engaged in real estate business. There was a survey u/s. 133A

K.RAMASWAMY ,MYSORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), MYSORE

In the result, both the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

penalty u/s. 271(1)(c) of the Act. ITA No.1866 to 1870/B/18 & Ors. Page 2 of 18 2. The assessee in the above appeals is Mr.R.Ajith. He is assessed in the status of an individual. He is engaged in real estate business. There was a survey u/s. 133A

SHRI. AJITH R,,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, MYSORE

In the result, both the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

penalty u/s. 271(1)(c) of the Act. ITA No.1866 to 1870/B/18 & Ors. Page 2 of 18 2. The assessee in the above appeals is Mr.R.Ajith. He is assessed in the status of an individual. He is engaged in real estate business. There was a survey u/s. 133A

SHRI. K. RAMASWAMY,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, MYSORE

In the result, both the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

penalty u/s. 271(1)(c) of the Act. ITA No.1866 to 1870/B/18 & Ors. Page 2 of 18 2. The assessee in the above appeals is Mr.R.Ajith. He is assessed in the status of an individual. He is engaged in real estate business. There was a survey u/s. 133A

K RAMASWAMY ,MYSORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1), MYSORE

In the result, both the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

penalty u/s. 271(1)(c) of the Act. ITA No.1866 to 1870/B/18 & Ors. Page 2 of 18 2. The assessee in the above appeals is Mr.R.Ajith. He is assessed in the status of an individual. He is engaged in real estate business. There was a survey u/s. 133A

MR. SHIVAKUMAR MAHADEVAIAH ,MYSORE vs. INCOME-TAX OFFICER, WARD-2(3), MYSORE

In the result, the appeal of the revenue is dismissed

Bench: Shri Chandra Poojari (Accountant Member), Shri Keshav Dubey (Judicial Member)

survey u/s 133A of the Act and paid tax accordingly on such additional income, we do not find any decision in levying penalty u/s 271

R G PATIL & COMPANY,HAVERI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

In the result, these 2 appeals of the assessee in ITA Nos

Bench: Shri George George K & Shri Laxmi Prasad Sahu

survey u/s 133A of the Act one of the partner Shri Kumar Gowda R Patil admitted that the loan was given to the parties and the source of the amount cannot be explained and accordingly offered the same for taxation. During the course of search proceedings, the statements were recorded u/s 132(4) on 19/6/2014 stating that

SIMRAN K SAYYED ,GADAG vs. INCOME TAX OFFICER WARD-1 , GADAG

In the result, assessee’s appeal for Asst

Bench: Shri N. V. Vasudevan & Shri Jason P Boazassessment Year : 2012-13 Ms. Simran. K. Sayyed, Vs. Income Tax Officer, Near Bhisma Tank, Ward - 1, Gadag – 582 101. Gadag. Pan : Bwgps 4895 G Appellant Respondent Assessee By : Ms. Mrinalini, Advocate Revenue By : Smt. Vikas K. Suryawamshi, Addl. Cit Date Of Hearing : 19.12.2018 Date Of Pronouncement : 04.01.2019

penalty of Rs.9,81,000/- u/s 271(1)(c) of the Income Tax Act, 1961 (in short ‘the Act’) for Assessment Year 2012-13. 2. Briefly stated, the facts relevant for disposal of this appeal are as under: 2.1 The assessee, engaged in real estate business, filed her return of income for Assessment Year 2012-13 on 17.09.2012 declaring

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty on the offered pursuant to a survey proceeding assessee. under section 133A of the Act. No - The CIT(A) has rejected IBM’s bonafide explanations were provided reference to the Punjab and Haryana under Explanation 1 of section 271(1)(c) HC’s ruling in CIT v. Rajiv Garg of the Act in respect of the income being

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty on the offered pursuant to a survey proceeding assessee. under section 133A of the Act. No - The CIT(A) has rejected IBM’s bonafide explanations were provided reference to the Punjab and Haryana under Explanation 1 of section 271(1)(c) HC’s ruling in CIT v. Rajiv Garg of the Act in respect of the income being

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty on the offered pursuant to a survey proceeding assessee. under section 133A of the Act. No - The CIT(A) has rejected IBM’s bonafide explanations were provided reference to the Punjab and Haryana under Explanation 1 of section 271(1)(c) HC’s ruling in CIT v. Rajiv Garg of the Act in respect of the income being

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty on the offered pursuant to a survey proceeding assessee. under section 133A of the Act. No - The CIT(A) has rejected IBM’s bonafide explanations were provided reference to the Punjab and Haryana under Explanation 1 of section 271(1)(c) HC’s ruling in CIT v. Rajiv Garg of the Act in respect of the income being

DCIT-CIRCLE-1(1), HUBLI, C.R. BUILDING , NAVANAGAR HUBLI vs. SHRI CHANDRASHEKHAR KOMMI, HUBLI

In the result, the appeal of the revenue is dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2015-16

survey u/s 133A and furnishing inaccurate particulars of work expenses.” 2.1 Such initiation of penalty proceedings was culminated into an order levying penalty to the tune of Rs.59,22,201/- u/s 271

IBM DEUTSCHLAND GMBH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1), BANGALORE

In the result, all the appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\n\nPage

IBM CANADA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION, CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

u/s\n139) and thereby contending that the\nAssessee had not disclosed all the facts\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect

IBM AUSTRALIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being\nsurrendered. The only argument made by\nthe Assessee was that it voluntarily\noffered receipts to tax and therefore,\npenalty cannot be levied.\n\nPage